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Cross-Border Tax (U.S.–Canada)

Toronto to Pittsburgh: AI Jobs, Pennsylvania's Flat 3.07%, and Local Wage Tax

Reviewed by the Fairlight Accounting cross-border tax team — U.S. & Canadian Tax Desks

On this page

Toronto's AI and software engineers have a market in Pittsburgh's AI, robotics, and autonomous vehicle companies, and its healthcare professionals in UPMC's system. The move is a large tax cut: Ontario's combined top rate of about 53.5% becomes about 43% inside Pittsburgh or about 41% in the suburbs.

Key takeaways

  • Ontario's roughly 53.5% top rate, including the provincial surtax, sets the departure tax. On a $300,000 unrealized gain, about $80,000.
  • Pennsylvania's flat 3.07% plus a 3% local earned income tax on Pittsburgh residents; suburbs charge about 1%.
  • Pennsylvania exempts most retirement income after retirement age.
  • 13% HST becomes 7% sales tax in Allegheny County.
  • OHIP ends on permanent departure. Keeping the Toronto home means NR6, Section 216, and the Vacant Home Tax if empty.

The Ontario departure

Departure tax applies to non-registered investments, private company shares, crypto, and foreign property at fair market value on the departure date. Ontario real estate, RRSPs, TFSAs, and pensions are excluded. Report on Form T1243, list holdings on Form T1161 if the total exceeds $25,000, and post security under Form T1244 for illiquid assets. The Toronto home: sell it under the principal residence exemption, rent it under NR6 and Section 216, or face Toronto's Vacant Home Tax if it sits empty. OHIP ends on permanent departure.

Pittsburgh's side

Pennsylvania's flat 3.07% state income tax; a 3% local earned income tax on Pittsburgh residents (1% city plus 2% school district), with most suburbs charging 1%; 7% sales tax in Allegheny County; property tax among the higher effective rates in the US, near 2% in Allegheny County after recent reassessments; no estate tax, but Pennsylvania's inheritance tax applies at 4.5% to lineal heirs, 12% to siblings, and 15% to others, with a spousal exemption.

The RRSP in Pennsylvania

Federally deferred under Article XVIII of the treaty. Pennsylvania taxes eight classes of income rather than starting from federal AGI, and it does not tax the undistributed earnings of retirement plans, which supports deferral. Pennsylvania also exempts most retirement income received after retirement age, which can cover RRIF withdrawals; document the position in the first-year file. Canadian withholding is 25% on lump sums, 15% on periodic RRIF payments within the treaty limit, with a US foreign tax credit federally.

Equity

RSUs vesting after the move are split by working days between Canada and the US; the state and any local authority tax their share. Both payrolls may withhold on the full amount; the excess is recoverable on the first-year returns.

Who makes this move

Toronto and Waterloo AI engineers to Pittsburgh's AI and autonomous vehicle companies, Toronto software developers to the city's tech employers, Ontario healthcare professionals to UPMC, and Toronto finance staff to PNC and the region's banks.

Worked example

A Toronto AI engineer moves to Pittsburgh on May 31 with $220,000 of unrealized gain in a non-registered account, $450,000 in an RRSP, RSUs vesting after the move, and a Toronto condo sold in the departure year.

  • Departure tax. $220,000 gain, $110,000 taxable, at about 53.5%: roughly $59,000.
  • Condo. Sold as a resident under the principal residence exemption.
  • RSUs. Vests split by working days; Pennsylvania and Pittsburgh tax their share.
  • RRSP. Federally deferred; Pennsylvania position documented.
  • Pittsburgh. State 3.07% plus 3% local. Combined top rate about 43%. HST 13% becomes sales tax 7%.

Official sources

"When you leave Canada, you are considered to have sold certain types of property (even if you have not sold them) at their fair market value (FMV) and to have immediately reacquired them for the same amount. This is called a deemed disposition and you may have to report a capital gain (also known as departure tax)." — Canada Revenue Agency, Leaving Canada (emigrants), https://www.canada.ca/en/revenue-agency/services/tax/international-non-residents/individuals-leaving-entering-canada-non-residents/leaving-canada-emigrants.html

Pennsylvania personal income tax is levied at the rate of 3.07 percent. — Pennsylvania Department of Revenue, Personal Income Tax, https://www.pa.gov/en/agencies/revenue/resources/tax-types-and-information/personal-income-tax.html

There are 5 Ontario income tax brackets and 5 corresponding tax rates. — Government of Ontario, Personal income tax, https://data.ontario.ca/dataset/personal-income-tax-rates-and-credits

The city earned income tax is levied at a rate of 1% on the wages or net profits earned by City residents. The City also receives a portion of the Earned Income Tax assessed by the Pittsburgh Public Schools equal to 2%. — City of Pittsburgh, Earned Income Tax, https://www.pittsburghpa.gov/City-Government/Finance-Budget/Taxes/Tax-FAQs

Practitioner note

Toronto-to-Pittsburgh clients budget correctly for the income tax cut and incorrectly for Allegheny County property tax, which on a like-for-like home is well above Toronto's. We put the property tax by municipality in the same spreadsheet as the income tax savings.

See also: Weighing Florida instead? See the Canada-to-Florida guide, or the same city's Toronto to Miami guide.

Next step

Fairlight prepares the Ontario departure return, the property filings, and the first-year federal, Pennsylvania, and local returns for Pittsburgh clients. See cross-border pricing or book a call.

Cross-border taxes, handled in one place

U.S. and Canadian filings prepared together by our U.S. and Canadian Tax Desks.

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